During the past decade in the pet food industry, pathogen related recallswere among the most frequent. Along with direct contamination bymicroorganisms such as Salmonella, ingredients tainted by fungal mycotoxins,like aflatoxin, have caused pet food recalls.

The United States Food and Drug Administration divides the removal of pet foodor treats from the market into three classes of recalls or as a withdrawal.Class one recalls are the situations that are the most critical, MicheleSayles, Ph.D., executive director of food safety and technology for DiamondPet Food, said during her Ask the Pet Food Pro presentation.

Class I recall: a situation in which there is a reasonable probabilitythat the use of or exposure to a violative product will cause serious adversehealth consequences or death.

Class II recall: a situation in which use of or exposure to a violativeproduct may cause temporary or medically reversible adverse healthconsequences or where the probability of serious adverse health consequencesis remote.

Class III recall: a situation in which use of or exposure to a violativeproduct is not likely to cause adverse health consequences.

Market withdrawal: occurs when a product has a minor violation that wouldnot be subject to FDA legal action. The firm removes the product from themarket or corrects the violation. For example, a product removed from themarket due to tampering, without evidence of manufacturing or distributionproblems, would be a market withdrawal.

Among these classes of recalls, four common types affect the pet foodindustry: mycotoxins, pathogens, foreign material and nutritional deficienciesor toxicities, she said. During the past decade in the pet food industry,pathogen related recalls were among the most frequent. Along with directcontamination by microorganisms such as Salmonella , ingredients tainted byfungal mycotoxins, like aflatoxin, have caused pet food recalls.

“The third biggest category for recalls has been nutritional deficiencies andtoxicities,” she said. “In the last two to three years, vitamin D has been onthe top of that list.”

Preventing pet food recalls with data management

Data management and analysis are critical to preventing these types of petfood recalls and dealing with them when they do occur, she said. For example,a pet food company needs this data to prove that they use statistically soundsampling procedures for incoming raw materials and outgoing finished products.

“The biggest asset or the biggest help is creating documentation, records andmost importantly data to support the robustness of your program and therobustness of your products.”

Tips for pet food recall rehearsal and preparation

It is better to be prepared for a pet food recall that never occurs than to beunprepared when a recall does occur. Beyond that obvious axiom, pet foodcompanies can take concrete steps to ensure a recall never happens and remainsmanageable if one does hit, Sayles said.

The fundamentals matter in pet food recall preparation, and the bedrock is aplan. Companies have a wide range of guidance to help them develop thoseprograms, including from the U.S. Food and Drug Administration, she said.Thinking beyond that plan, into the administration of implementation such asphone trees, make the plan more practical.

“What are some of the things that you do outside of just the actual recallplan?” she asked. “Who are you going to call? What customers to call?”

Mock recalls help pet food companies refine their ability to locate andretrieve finished products. Traceability becomes key.

“A good rule of thumb is one step forward, one step back,” she said. “One stepforward would be finished product traceability and one step back would beingredients.”

Within the ingredient category, differences between minor ingredients andmajor ingredients need to be considered, she said, such as vitamins andminerals versus carbohydrate and protein sources.

Pet food companies must prepare to roll with these plans quickly, she said. Inaudits, identifying choke points that slow the process can revealopportunities for improvement.

“Obviously, the more you practice them, the better that you get,” she said.

Lot coding and data management play an important role in traceability.

“For example, if you identify an issue with a particular ingredient, and ithas a lot code that extends for months that could create issues as far as howmuch product you’re going to have to recall,” she said.

Data management is critical in a pet food recall program. A data-driven recallprogram can provide more than just a means to trace a specific lot of acertain ingredient. In a world of skeptical consumers, information of howproducts are made helps prove pet foods are safe and made to specifications topet owners as well as health inspectors.

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